What is an inventory search?

When a vehicle is lawfully impounded, officers may inventory its contents. The stated purposes are protecting the owner's property, protecting the agency against claims, and officer safety.

The critical requirement is that it be conducted according to standardized departmental procedures. That's what separates an inventory from an investigative search, and it's the thing that gets litigated.

What that means practically. The agency must have a written policy. The policy has to govern what gets opened and how. The impound itself has to have been lawful — an inventory can't justify a search where there was no proper basis to tow the car in the first place. And the search has to actually look like an inventory, meaning a completed inventory form listing items.

Where officers deviate from the policy, or where the record shows they were looking for evidence rather than cataloguing property, the search loses its justification.